New EU packaging rules (PPWR) and what it means for your wholesale operations

On 12 August 2026, Regulation (EU) 2025/40 — the Packaging and Packaging Waste Regulation, or PPWR — replaces the directive that has governed EU packaging since 1994. Because it's a regulation rather than a directive, it applies directly in all 27 member states, without each country writing its own version first.

Most coverage of the PPWR is written for large manufacturers. If you're a small or mid-sized brand selling wholesale to independent retailers across Europe, a handful of provisions matter far more than the rest. Here they are:

You may count as a "producer" in every country you ship to

Under the PPWR, extended producer responsibility (EPR) falls on the operator that first makes a packaged product available on the market in a given member state. That isn't necessarily whoever manufactured the packaging. It's whoever puts it on that country's market first.

For a wholesale brand, this is the provision to read twice. If you're based in the Netherlands and you ship an order to a concept store in Lyon, you are plausibly the first to make that packaging available in France. Ship to Germany, Belgium, Denmark and Italy too, and the question repeats in each.

Registration under Article 44 is national, not European. A Dutch registration doesn't cover France. And the regulation is explicit that producers must not make packaging available in a member state where they — or their appointed representative — aren't registered.

Most brands are registered in their home market and nowhere else. If you export wholesale, that gap is worth mapping this month.

Being small doesn't exempt you

There's a persistent assumption that packaging rules only kick in above some revenue or headcount threshold. The PPWR contains no general exemption for micro or small enterprises from the core registration, reporting and design obligations.

There is relief on paperwork: producers placing under 10 tonnes of packaging on a national market get a simplified annual reporting dataset. That's a lighter report — not permission to skip registering.

Three things that change on the date itself

Declarations of Conformity become mandatory. From 12 August, packaging placed on the EU market needs a Declaration of Conformity covering minimisation, recyclability, recycled content, restricted substances and reuse classification. You probably don't produce your own packaging — but your packaging suppliers are obliged to give you the documents evidencing conformity. Request them in writing now, and keep them: five years for single-use packaging, ten for reusable.

PFAS limits on food-contact packaging, with no sell-through period. If you sell food, tea, confectionery or anything else in food-contact packaging: there is no transitional period for exhausting old stock. Packaging placed on the market after 12 August must meet the limits. Stock already placed on the market before that date can remain.

The old directive is repealed. Directive 94/62/EC falls away on 12 August. National schemes still sit underneath the regulation — Germany's new packaging act takes effect the same day, with existing system participations there valid until 31 December 2026 — so the practical answer in each country still depends partly on national law.

What's coming, and why it affects your next packaging order

Packaging tooling and print runs have long lead times, so it belongs in decisions you're making now.

• 12 August 2028 — harmonised labelling of material composition, to help consumers sort correctly.

• 1 January 2030 — only recyclability grades A (≥95% recyclable by weight), B (≥80%) and C (≥70%) may be placed on the market. Minimum recycled content thresholds apply to plastic packaging.

• 1 January 2030 — empty space in grouped, transport and e-commerce packaging capped at 50%. If you ship in oversized cartons padded out with paper or air cushions, this is the one to plan around.

• 1 January 2030, rising by 2040 — transport packaging reuse targets of 40%, then 70%.

If you're specifying new retail packaging in the next 18 months, brief it against the 2030 grades rather than re-tooling twice.

If you're based outside the EU

Non-EU brands are in a tighter spot. Producers must appoint an authorised representative for EPR in each member state where they're not established. A proposal to suspend that requirement was aimed at EU-established producers only — third-country producers were deliberately left out and remain fully in scope from 12 August. The suspension didn't pass for EU producers either: the Council dropped the EPR provisions from its negotiating mandate in June 2026.

If you're a UK, Swiss or US brand selling into the EU, treat this as immediate rather than as next year's problem.

Where to start

1. List every EU country you shipped wholesale orders to in the past 12 months.

2. Check your EPR registration status in each one — not just your home market.

3. Email your packaging suppliers and request Declarations of Conformity.

4. Weigh your packaging by material. Every national report asks for this.

5. Brief any new packaging against the 2030 recyclability grades.